Allowing the appeal of the assessee the Court held that the proper test to be applied was not the nature of the new line of business, which was commenced by the assessee, but unity of control, management and common fund. This issue was never disputed by the Assessing Officer or the appellate authorities. The authorities had concurrently held that it was the assessee who had commenced the business and the assessee would mean the assessee-company as a whole and not a different entity. Therefore, when there was commonality of control, management and fund, those would be the decisive factors to take into consideration and not the new line of business, namely, the textile business. Before the Commissioner (Appeals) a specific ground had been raised stating that the Assessing Officer ought to have appreciated that the decisive factors for allowance were unity of control, management, interconnection, interlacing, interdependent, common fund, etc., and if the above factors were fulfilled, then the expenditure should be allowed even if the project was a new one. The Commissioner (Appeals) did not give any finding on such a ground raised by the assessee. Therefore, it was incorrect on the part of the Department to contend that such a question was never raised before the appellate authorities. ( AY. 2000-01 )